Letter outlines recommendations to strengthen Payment Account framework through clear standards, proportionate oversight, and regulatory consistency

Washington, D.C. (July 27, 2026) – The American Fintech Council (AFC), the largest industry association representing both responsible fintech companies and innovative banks, submitted a letter to the Federal Reserve in response to its proposed revisions to its Policy on Payment System Risk and the Guidelines for Account and Services Requests concerning the establishment of Payment Accounts. The letter supports the Federal Reserve’s effort to modernize access to payment infrastructure through a specialized Payment Account framework and recommends improvements to strengthen eligibility standards, regulatory consistency, and responsible access to payment infrastructure.

“The Federal Reserve’s proposed Payment Account framework represents an important opportunity to adapt to the evolving payments ecosystem," said Phil Goldfeder, CEO of the American Fintech Council. "A transparent framework that aligns operational safeguards with the specialized purpose of the Payment Account can promote competition, improve payment efficiency, and support responsible innovation while preserving the integrity of the Federal Reserve System."

AFC supports the Federal Reserve's proposed risk-based Payment Account framework as a critical step toward expanding responsible access to payment infrastructure while preserving the safety and soundness of the financial system. To strengthen the framework, AFC encourages the Federal Reserve to establish objective eligibility standards that promote regulatory certainty, transparency, and consistent supervisory outcomes. Additionally, the letter calls for clearly defined, proportionate operational safeguards that preserve the specialized nature of the Payment Account while promoting responsible innovation.

“The long-term effectiveness of this framework will depend on a regulatory approach that emphasizes proportionate supervision, regulatory consistency, and long-term adaptability,” said Ian P. Moloney, Chief Policy Officer at the American Fintech Council. “A thoughtful implementation approach that builds on existing supervisory practices will provide the clarity needed for institutions to responsibly engage with this new framework while supporting the continued evolution of the payments ecosystem.”

AFC also encourages the Federal Reserve to implement the Payment Account framework through a principles-based approach that promotes regulatory consistency and long-term innovation. The letter recommends coordinating implementation across federal regulators, leveraging existing supervisory and compliance frameworks, and avoiding duplicative regulatory requirements that increase burden without improving oversight. AFC further urges the Fed to periodically evaluate and refine the framework to ensure it remains responsive to evolving payment technologies, market practices, and supervisory capabilities.

A standards-based organization, the American Fintech Council (AFC) is the largest and most diverse trade association representing financial technology (fintech) companies and innovative banks. On behalf of over 150 member companies and partners, AFC promotes a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.

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